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The business and tax landscapes have changed dramatically, and the pace and complexity of change continues to increase. We can help you navigate this shifting landscape. Governments are tempering the need for revenue with increased competition for labor and capital. Tax authorities are adapting their enforcement strategies, focus and policies in response to the changing dynamics of business. Companies are balancing competing priorities, ensuring they maintain compliance while adding value. We can assist you with these critical issues in today's tax environment, including:
The global tax landscape continues to change in a dramatic fashion, with near-constant news hitting the headlines regarding shifting tax policy, increasing levels of enforcement and the growing potential of reputational risk.
Competing priorities
Multinational companies now have to balance more competing priorities than ever before, ensuring they protect their business by monitoring and responding to changes in policy, legislation and tax enforcement, while at the same time ensuring they not only maintain the highest levels of compliance but also add value from the tax function.
Governments work to secure each tax dollar they're due
From a policy perspective, all governments want their country to be viewed as an attractive place to do business, to attract jobs and capital in an increasingly competitive globalized arena.
At the same time, they want to increase the amount of revenue they bring in. Governments are treading a fine line, constantly assessing how to secure the tax revenues they see as rightly theirs, while at the same time being in direct competition with other nations, making sure they do not scare off mobile capital.
Tax administrations for their part are adapting their enforcement strategies, focus and policies in response to the changing dynamics of business. They are working to ensure that their resources are being applied to the right issues and taxpayers. They share more leading practices and taxpayer information with their foreign counterparts, to help them collect every dollar due.
Disputes are on the rise
The result has been more frequent, complex and higher value disputes between taxpayers and taxing authorities — a trend that is only increasing as countries collaborate together and as emerging markets gain in stature and influence, taking a more sophisticated approach to taxation. Penalties are becoming more stringent and the threat of reputational risk has risen significantly in recent months.
We can help you to navigate a route through this complex landscape.
We can help you monitor and react to quickly-changing tax policy and assess the economic and fiscal impact.
Where tax policies might create an impediment to your business that is unintended by policy makers, we can help you to collaborate – either solely, or as part of a broader grouping of companies who share a common objective – with government to:
Explain the impediment
Develop alternative policy choices which are logical and well thought out
Model the potential outcomes
Deliver an alternative choice to the government in a form with which policy makers can comfortably work
We also help you address your global tax controversy, enforcement and disclosure needs.
We focus on pre-filing controversy management to help you properly and consistently file your returns and prepare the relevant back-up documentation.
Where a controversy has already occurred, our professionals leverage the network's collective knowledge of how tax authorities operate, and increasingly work together, to help resolve difficult or sensitive tax disputes. To ensure that continuous performance improvements are instigated after a controversy, we work with EY's other tax professionals to ensure that similar events are less likely to occur.
Below you can access our views and analysis of some of the substantial policy and enforcement trends and issues at play today.
Global Compliance and Reporting (GCR) is at a tipping point. Many companies distribute responsibility for GCR processes throughout their organization creating a patchwork. The results are suboptimal. Our recent survey shows a need for a new approach.
Due to the combination of evolving business models, transforming finance functions and an increasingly complex regulatory landscape. There are new opportunities to better optimize efficiency, control and value, to help mitigate risk and improve performance.
What is Global Compliance and Reporting?
GCR comprises the key elements of a company's finance and tax processes that prepare statutory financial and tax filings as required in countries around the world. These duties include:
Statutory accounting and reporting
Tax accounting and provisions
Income tax compliance
Indirect tax compliance
Governance and control of the above processes
GCR activities reside in the middle of a broader set of so-called record-to-report (R2R) processes. R2R is the intersection between any company's finance and tax departments and is used to capture, process and store information that is essential to statutory accounting, tax compliance and reporting. Any change to R2R processes, information, finance systems, roles and responsibilities will have a direct impact on GCR processes.
Risk on the rise
GCR risks are on the rise. Local jurisdictions are rewriting regulations, focusing more intently on the collection of tax revenues and sharing more taxpayer information across borders. At the same time, the global financial crisis has driven companies to redesign their finance operating models to remain competitive and to take advantage of opportunities for growth.
Our new report Seizing the opportunity in Global Compliance and Reporting investigates the significant developments taking place as multinational companies determine the best way to meet financial reporting and tax obligations worldwide.
Our case study highlights how we helped leverage an array of external providers
Helping you achieve meet the new GCR demands
Fast changing compliance and reporting requirements are more demanding on tax and finance functions today than ever before. So how do you improve control and quality, manage risk, create efficiency and drive value?
Our market-leading approach combines standard and efficient processes, highly effective tools and an extensive network of local tax and accounting subject matter professionals.
See more on how we can help you meet the demands of today's tax landscape
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Transfer Pricing and Operation Model Effectiveness
We are excited to share our latest Tax Alert, which addresses the issuance of new payroll-related regulations concerning the relief provided on tax and social security for workers in certain industries.
On 31 December 2024, Indonesia issued Implementing Regulations on Global Minimum tax under BEPS 2.0 Pillar Two, which includes Income Inclusion Rules, Domestic Top-up Tax, and Undertaxed Payment Rules.
The regulation is effective for fiscal years beginning on or after 1 January 2025. There will be obligations to submit a Top-up Tax Return for GloBE, DMTT, and/or UTPR, a GloBE Information Return (GIR), and a Notification.
On 31 December 2024, Indonesia Minister of Finance (MoF) issued Regulation No 131/ 2024 (“PMK-131”) in relation to New VAT Treatment. PMK-131 is the implementing regulation of Article 8A of Law No 8/1983 (VAT Law) which was last amended by Law No. 6/2023. PMK-131 is effective on 1 January 2025.
We are pleased to bring you our latest Tax Alert regarding the Directorate General of Taxation (“DGT”) regulation PER - 2/PJ/2024 (“PER-2”). The regulation introduces new forms and procedures for the reporting of withholding tax on payments to individuals under Article 21 and Article 26 of the Income Tax Law (“WHT21/26”). PER-2 revokes DGT regulation PER-14/PJ/2013. Some forms have been updated and a new form introduced as part of the mechanism update provided under PER-2. The changes to the forms are mainly to accommodate the change of WHT21 calculation based on the newly issued regulations, i.e. Government Regulation No. 58/2023 and Minister of Finance Regulation No. 168/2023 (“PMK-168”), as well as the use of NIK as NPWP (i.e. the national ID number in lieu of tax ID number).
We are pleased to bring you our latest Tax Alert regarding the Indonesian Government regulation No 58/2023 (Government Regulation 58, “GR 58”) and the related implementing regulation, i.e. Minister of Finance regulation No 168/2023 (“MoF 168”) in relation to the Tax Rate for Withholding Income tax Art 21/26 (“WHT 21”).
The Indonesian Ministry of Finance has issued Minister of Finance Regulation number 172 of 2023 regarding the Implementation of the Arm’s Length Principle in transactions affected by a Special Relationship (PMK 172). PMK 172 addresses topics including application of the arm’s length principle, transfer pricing documentation requirements, Advanced Pricing Agreements (APAs) and the Mutual Agreement Procedure (MAP). PMK 172 entered into force on 29 December 2023.
22 January 2024
2023
New regulations impacting business visitors to go into effect by 23 October 2023
On 22 August 2023, the Indonesian Ministry of Law and Human Rights issued Regulation Number 22 on Visas and Residence Permits, which went into effect on 24 August 2023. The government is expected to begin implementing changes pursuant to the new regulation within 60 days of the regulation going into effect (i.e., by 23 October 2023).
17 October 2023
New Golden Visa route introduced
On 22 August 2023, the Indonesian Ministry of Law and Human Rights issued Regulation Number 22 of 2023 on Visas and Residence Permits, which went into effect on 24 August 2023. The Regulation establishes into law the new Golden Visa route, which authorizes individuals to reside in Indonesia for up to 10 years and provides them access to priority services at immigration offices, check points and related entities. Individuals who successfully apply under the Golden Visa route will be granted a Temporary Stay Visa (VITAS), Temporary (ITAS) or Permanent Stay Permit (ITAP), and Re-entry Permit under one of the four categories below. The government is expected to begin accepting applications under the Golden Visa route within 60 days of the new law going into effect (i.e., 23 October 2023).
4 Oktober 2023
New Government Regulation on Taxation of Benefits in Kind
Tax Alert regarding Government Regulation No. 55 Year 2022 (“GR-55”) issued on 20 December 2022 as implementing regulation on the Income Tax Law, which was last amended by Law No. 7 Year 2022 (Tax Regulations Harmonization Law). One section of GR-55 provides details on new regulations regarding Benefits in Kind, which is the focus of this alert.
12 January 2023
2022
Update on construction service regulations
We are pleased to bring you our latest Tax Alert regarding Government Regulation No 9/ 2022 (GR-9) on the update of taxation on construction services. GR-9 is a second amendment of GR No 51/2008 (GR-51), which was previously amended by GR No 40/2009 (GR-40). GR-9 is effective on 21 February 2022.
11 April 2022
2021
Wide ranging taxation changes in Indonesia under Tax Regulation Harmonization Law
We are pleased to bring you our latest Tax Alert regarding Tax Regulations Harmonization Law (“HPP Law”) which become Law No.7/2021 on 29 October 2021. The changes under the HPP Law are very significant and wide-reaching. There are changes not only to administrative matters but to key aspects of the Income Tax and VAT Laws. The provisions take effect at varying times – e.g., for income tax purposes from the 2022 Fiscal Year and VAT purposes from 1 April 2022.
1 December 2021
Technical Guidance for the Implementation of Mutual Agreement Procedure
On 10 September 2021, Directorate General of Taxation (DGT) released Circular Letter SE-49/PJ/2021 (SE-49), Technical Guidance for the Implementation of Mutual Agreement Procedure (MAP), intended to provide guidance for the DGT to follow up requests for the implementation of MAP and, as such, is largely focused on the DGT’s internal process.
15 October 2021
Reduced withholding tax rate on bond interest
Our latest Tax Alert regarding Governor Regulation for DKI Jakarta No 60/2021 (“GR DKI - 60”) regarding 2021 fiscal incentive given for DKI Jakarta area. The purpose of GR DKI-60 is to provide economic relief to residents of DKI Jakarta who are impacted by COVID-19. GR DKI-60 is effective on 16 August 2021.
29 September 2021
2021 Fiscal Incentive for DKI Jakarta
Tax Alert regarding Governor Regulation for DKI Jakarta No 60/2021 (“GR DKI - 60”) regarding 2021 fiscal incentive given for DKI Jakarta area. The purpose of GR DKI-60 is to provide economic relief to residents of DKI Jakarta who are impacted by COVID-19. GR DKI-60 is effective on 16 August 2021.
31 August 2021
Implementing guidelines on the investigation of COD
Tax Alert regarding the implementing guidelines on the investigation of foreign taxpayer’s certificate of tax domicile as stated under the Director General of Taxation Circular Letter No 35/PJ/2021 issued on 31 May 2021.
18 June 2021
Tax treatments on income from the sales of Phone Credit, SIM Card, Electricity Token and Voucher
Tax Alert regarding the release of the Minister of Finance Regulation No 6/PMK.03/2021 (“PMK-6”) regarding VAT and income tax treatments on the sales of phone credit, SIM card, electricity token (“token”), and voucher.
16 April 2021
Further extension in response to COVID19 crisis
Tax Alert regarding the release of the Minister of Finance Regulation No 9/PMK.03/2021 (“PMK-9”). PMK-9 expands the business sectors that are eligible to obtain the COVID-19 tax incentives, and extends the tax incentives period by six months, through to 30 June 2021.
12 April 2021
Stamp duty payment, validity of stamp, and postdated stamp duty
Tax Alert regarding the Minister of Finance regulation No 4/PMK.03/2021 (“PMK-4”) regarding stamp duty payment, validity of stamp, and postdated stamp duty. PMK-4 is the implementing regulation of the new Stamp Duty Law (i.e. Law No 10/2020).
12 April 2021
Further details released on Omnibus Law tax treatments
Tax Alert regarding Government Regulation No 9/ 2021 (“GR-9”) and Minister of Finance regulation No. 18/PMK.03/2021 (“PMK-18”). GR-9 and PMK-18 provide some further details on income tax, VAT and general tax provisions and procedures (“KUP”) provisions under Law No. 11/2020.
12 April 2021
Indonesia notification on MLI BEPS
Tax Alert regarding Indonesia notification on its completion of its internal procedures for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting. Indonesia confirms completion of its internal procedures for the entry into effect of MLI changes for 22 tax treaties – treaty changes in effect from 1 January 2021.
Our dedicated tax professionals can help you address tax risk, better manage tax controversy and resolve tax disputes wherever you do business. Learn more.
Our tax team can help you develop an effective operating model and transfer pricing policies that help your business achieve its potential. Learn more.